Question: We are a US-based company that manufactures and sells medical equipment.Our foreign subsidiaries are selling our medical equipment to customerslocated in Iran using approved licenses received from OFAC. We recentlystarted receiving requests from our foreign subs asking for approval toprovide “equipment repair” and “warranty services” to these Iraniancustomers for the equipment we have […]
Question: I am interested in learning about industry practice concerning routedexports & licensable shipments. Our international trade team has drafted acommunication about routed exports and the associated risks. The policy tobe rolled out will prohibit routed export transactions for licensableshipments or those that require a DEA permit. Is this too conservative? Our commercial group is […]
Question:Does anyone have any recommendations for export control warning language that should be placed on product that is controlled for export under the EAR to certain countries?
Question:I am experienced at imports and new to exports. So, I am going to audit my exports. I am looking for data elements to check for under the following scenarios: 1- Basic audits: The 1 in 10 you do to keep your FF honest and to make sure murphy’s law is not working on your […]
Question:Does anyone have any recommendations for export control warning language that should be placed on product that is controlled for export under the EAR to certain countries?
Question: I want to send a sealing machine to my DC in the EU. It uses directed RF toseal clam shells. My question is will i need an export license for this orcan i just use a license exception for intercompany transfers
Question: Is there a process for finding out if a company is already registered withDDTC before going through the application process? ========================= Answers: The process I use is to request the party confirm in writing whether ornot they are registered. ========================= The only way that I can think of is to call DDTC and ask. […]
Question: Here is the scenario: Our Company is the USPPI (Manufacturer) in a Routed Export Transaction to Japan. The FPPI (Customer) located in Japan has accepted responsibility for all US export formalities by means of its US Agent (Freight Forwarder). We manufactured the product and delivered it to the FPPI’s US Agent along with the […]
Question: In a routed export transaction, is the USPPI or the FPPI responsible for the TSA screening?
Question: We might be exporting some chemicals, and I am trying to find out if we needto register these chemicals in other countries. The items are currentlyregistered with the EPA and are manufactured in the US. We are not themanufacturer. We will be a distributor, and the current manufacturer doesnot ship outside the US. I […]
Question: Question for the masses. When we have a customer who requests us to ship to a forwarder, but bill them domestically, we consider that a domestic sale and are not listed as the exporter when the parts are later shipped. If the Bill To address is in another country and we are requested to […]
Question: For those who have a program in place to collect End-User statements for export orders, 2 questions: Is there any reason that an End-User statement should be required for each & every P.O./shipment or is it OK to collect a blanket statement from each customer? If a blanket is OK, can it be […]
